Commission on the Defence Forces Public Consultation Response

THE NAVAL SERVICE DIVING SECTION – THE DEVELOPMENT OF THE STATE’S MILITARY UNDERWATER CAPABILITY

NAVAL SERVICE DIVING SECTION

1. Capabilities – In this regard, you may wish to consider future integrated capability development and the planning and delivery requirements to support a joint force approach in terms of new equipment, professional military education and training, maintenance and development of infrastructure, developments in military doctrine, and transformative concepts, including specialist capabilities, that prepare and support the Defence Forces for future operations.

NAVAL SERVICE DIVING CAPABILITY

Currently, the Naval Service has overall responsibility for Military Diving within the Defence Forces. The Naval Service Diving Section (NSDS) was established in the early 1980’s and now operates a large range of diving systems, including Self Contained Underwater Breathing Apparatus (SCUBA), Surface Supplied Diving Equipment (SSDE) and Mixed Gas Rebreather Systems. The NSDS also has a range of underwater robotics & survey equipment; including 2 x “REMUS 100” Autonomous Underwater Vehicles (AUVs), 3 x remotely operated Vehicles (ROVs), Side Scan Sonar Equipment, an Ultra Short Baseline (USBL) Acoustic Positioning System, amongst various other underwater systems.

International military best practice places the responsibility for countering all underwater explosive ordnance disposal, and improvised explosive devices found below the high-water mark, with Navies. In recognition, the White Paper on Defence 2015 (WP2015) delegates the responsibility for “the clearance of underwater mines and explosives” to the Naval Service Diving Section (para 3.5.1). Underwater Control, covering Harbour Protection and Mine Warfare operations, falls within the 2018 EU Capability Development Plan, where Underwater Control is one of eleven cross domain capability priority areas. The EU have developed the Strategic Context Case on Underwater Control as a vehicle for implementation to address capability shortfalls in this area at an EU, and national level through the Project Team Underwater Control. PESCO Projects such as Maritime (Semi) Autonomous Systems for Mine Counter Measures (MAS MCM) in which Ireland are observers; and the PESCO Harbour and Maritime Surveillance and Protection Project (HARMSPRO) are all aligned with addressing these capability shortfalls in both Mine Warfare and Critical Infrastructure Protection and the protection of Sea Lines of Communication, vital for an island nation such as ours. The volume of sub-sea internet & cyber cables being routed to Ireland, and the fact that 99% of Ireland’s trade is conducted by sea, further highlights the need for the State to protect its Sea Lines of Communication.

WP2015 also highlights that "many of the risks and threats listed in the EU Maritime Security Strategy (EUMSS) are relevant to Ireland's maritime domain" (para 2.5.4). In the context of critical seabed and port infrastructure, WP2015 references the EUMSS Action Plan and the protection of critical maritime infrastructure as one of its five (5) workstrands (para. 3.4.4). The EUMSS lists underwater pipes and cables as being a strategic maritime interest for the EU. The ability to map and survey these pipes and cables, which are easily interfered with over the horizon, to a detailed hydrographic survey standard ensures that Ireland can accurately monitor them, ensure that their physical security remains intact and that any physical disruption can be identified, responded to and countered/secured.

To develop the capabilities required to address identified shortfalls and threats to our Sea Lines of Communication, our lifeblood as an island nation, and bring Ireland in line with international best practise, requires additional resources invested in both human resource, equipment and infrastructure into the NSDS.

2. Structures – In this regard, you may wish to consider the most effective high-level Command and Control (C2) structures within the Defence Forces to ensure an agile and balanced approach that can function across all domains at home and overseas.

Additionally, you may wish to address appropriate future force structures for the Army (including its brigade structure), the Air Corps, and the Naval Service, individually as component services and collectively as part of an integrated joint force approach.

Furthermore, you may wish to address the changing nature of reservists, which presents an opportunity for the Reserve Defence Force to further integrate and support the Permanent Defence Force through the provision of enhanced collective and specialist capability across all domains. NAVAL SERVICE DIVING SECTION

Despite a significant increase in NSDS responsibilities over recent years, which has seen significant investment in both diving and underwater search equipment, the structures and manning levels of the NSDS have gone largely unchanged.

Currently, the NSDS falls under the command of Officer Commanding Shore Operations as follows:

NAVAL HQ (FOCNS)

OPERATIONS SUPPORT NAVAL COLLEGE COMMAND COMMAND (OC & CNC) (OCNOC) (OCNSC)

SHORE OPS NS FLEET NAVAL INT. FORST

NSDS

It is proposed that this C2 structure be amended to reflect the NSDS as the State’s primary diving asset:

NAVAL HQ (FOCNS)

OPERATIONS SUPPORT NAVAL COLLEGE COMMAND COMMAND (OC & CNC) (OCNOC) (OCNSC)

NSDS SHORE OPS NS FLEET NAVAL INT. FORST NSDS

This would ensure that the Head of Military Diving in the Defence Forces is at an appropriate level in the C2 structure of the organisation and has a seat at the decision-making table. This will prevent dilution/mis-interpretation of key information as it travels up and down the Chain of Command.

3. Staffing – In this regard you may wish to consider the HR policies that support the requirement for an agile and adaptive modern military force. You may wish to consider issues such as recruitment and retention, organisational culture and values, gender and diversity, career progression, and industrial relations machinery.

ESTABLISHMENT OF A NAVAL SERVICE CLEARANCE DIVER BRANCH

Currently the Establishment of the NSDS is twenty-seven (27), broken down as per “Annex A” to this submission. Divers are primarily drawn from the “Seamans” Branch of the Naval Service and continue to operate a two (2) year seagoing/ashore rotation in line with the rest of the Naval Service. This rotation is detrimental to the proficiency and development of Naval Diving as individuals are affectively “re-learning” the equipment and re-training to gain proficiency each time they rotate ashore.

As Naval Diving is classified as an “Additional Qualification” within the Naval Service, it comes secondary to an individual’s primary “Branch” (Seamans, Mechanicians, Supplies, Communications etc.) Naval Diving, although highly specialised and technical in its nature, always takes a back seat.

Due to the seagoing/ashore rotation and the “Additional Qualification” status of Naval Diving, the NSDS is currently operating at 44% Strength, including Support Staff. There are currently seven (7) “in-date” Divers posted into the NSDS. The NSDS has very limited operational capability and over the past 24 months, the NSDS was unable to respond to several ATCP/ATCA requests.

When the NSDS can respond, Divers are attached from other Units whenever operations dictate. This results in Divers of different proficiency levels operating on the same Dive Team, which can slow down operations. The training burden of running Diving Courses also draws on the limited resources of the NSDS, further diminishing operational capability. Due to the lack of staff, the majority of diving equipment maintenance is now outsourced to private contractors, which leads to further decline in equipment knowledge and proficiency.

By way of illustrating the critical manpower shortages in the NSDS, the minimum Dive Team required for the most basic of diving operations is six (6) - Dive Supervisor, two (2) x Divers, Standby Diver, Surface Attendant and a Boat Coxswain. At the time of writing, there are twenty-six (26) in- date Divers in the Naval Service, but only seven (7) of these are posted to the NSDS. Two (2) of these seven (7) are eligible for the next 6-month Potential Non-Commissioned Officers Course, due to commence next month. In order to maintain future diving capability, there is a requirement to qualify more 18m Dive Supervisors. Due to other factors later in the year, the 18m Dive Supervisors Course (5 weeks) must be run during the same period, with three (3) students and two (2) instructors drawn from the NSDS. Therefore, there will be a six (6) month period where the NSDS could be reduced to five (5) Divers. Within that six (6) month period, there could be a further five (5) week period where the NSDS can only respond to the most basic of diving tasks by pausing a CPD Course and augmenting the Dive Team with a Diver from another Unit. This is just one example of the cycle of continuous manpower issues within the NSDS.

Military Diving has, by its very nature, an inherently higher risk factor than most other routine military operations. Divers are tasked with conducting operations in nil visibility on submerged hazards like sunken fishing vessels, aircraft and vehicles in waters affected by strong currents. The complexity of diving operations such as the Search & Recovery operations for Irish Fishing Vessel WD-207 “ALIZE” in 51 m of water (January 2020) or the Irish Coastguard helicopter “R116” in 42m of water (March 2017) cannot be understated.

In order to maintain current operational capability and diving proficiency, develop future capabilities as mentioned in Section 1 above; and in keeping with international norms, it is proposed that a “Clearance Diver” Branch be established within the Naval Service and that the Support Staff within the NSDS be augmented.

“Clearance Diver” is an internationally recognised term for full-time specialist divers who undertake diving operations such as underwater searches, salvage, demolitions, Explosive Ordnance Disposal (EOD) and Improvised Explosive Device Disposal (IEDD). Examples of Clearance Diving tasks are as follows:

(a) Search for and clear sea mines which cannot be dealt with by other means.

(b) Conduct seabed searches in open and enclosed waters using divers, ROVs and AUVs.

(c) To render safe as necessary and recover, or assist in the recovery, from the seabed of any objects which contain explosive material including sea mines and Special Weapons.

(d) EOD and explosive aspects of salvage operations including recovery of crashed aircraft and vessels.

(e) Operate from Vessels to identify mine like contacts for subsequent recovery, disposal, or neutralisation.

(f) Explosive Ordnance Disposal (EOD) in or under the water, including Improvised Explosive Devices.

(g) Perform explosive demolition tasks afloat or underwater, including Beach Obstacle Clearance in support of Amphibious Operations.

(h) Carry out all forms of underwater search on ships, structures and seabed, including high risk searches.

(i) Provide Maritime EOD Force Protection (MEOD-FP) capability to the Fleet.

(j) Carry out In Water Maintenance and Repair (IWMAR) tasks and Battle Damage Assessment and Repair (BDAR).

(k) Support Special Forces Operations.

Occasionally, the NSDS sends personnel on international Clearance Diving Courses. Again, these are seen as “Additional Qualifications” and these personnel continue to operate a two (2) year seagoing/ashore rotation. Currently, there is no continuous professional development or any follow-on training for these individuals once they return to the Naval Service and this is leading to issues with Underwater EOD proficiency within the Defence Forces.

The structure of these proposed changes are attached at “Annex B” to this submission.

From a Naval Diving perspective, this will mean that an individual can follow a defined career path as a Clearance Diver. These Divers would be trained in all the NSDS’ Dive Systems (SCUBA, SSDE,

Mixed Gas), underwater robotics & survey equipment and in Underwater Explosive Ordnance Disposal (UW EOD).

In order for the Naval Service to gain maximum benefit from these individuals, it may be worthwhile imposing a stipulation that before an individual can apply for selection and training as a Clearance Diver, they must have completed their first Term of Engagement. They can then apply for a change in career path through a Technical Trainee Scheme, the mechanisms of which are already well established within the Naval Service.

In order to widen the pool of potential candidates, the Scheme could be opened up to the whole Defence Forces.

It is envisaged that the upper level of the structure (Cdr, Lt Cdr, WO/Diver & SCPO/Diver) would form “The Office of Superintendent of Diving”, “Directorate of Dive Safety” or a similar governing body, responsible for the oversight and governance of all Defence Forces Diving (Naval Service, Army Ranger Wing and additionally as required) and in accordance with International Best Practice for the oversight on diving standards. The office would act as the military point of contact with the relevant Irish authorities in the context of the Diving at Work regulations of the State. This office would also be responsible for the career management of the Clearance Diver Branch.

Operations Department: This department would be responsible for all day-to-day Military Diving Operations. Sub-divided into three (3) teams (DT1,DT2 & DT3), this would allow flexibility for individuals to avail of Career/CPD Courses etc. without affecting operational capability. It also allows for scope to deploy a Dive Team with a unit for overseas missions like EUNAVFOR MED Operation PONTUS & Operation SOPHIA. Between operations, currency and proficiency training on the full range of diving equipment and systems would ensure full operational capability & effectiveness.

MCM/EOD Department: In order to maintain proficiency in Underwater EOD (UW EOD) and respond to ATCP requests as per WP2015 requirements, a dedicated MCM/EOD Department should be established. This department should have close links with the Defence Forces Ordnance Corps and School of Ordnance.

Maintenance Department: From a Support Staff perspective, this will mean that the NSDS will have the appropriate levels of technicians available to maintain and service the wide array of equipment available to the Clearance Divers. The Diver Support Staff element would be specifically responsible for the service and maintenance of all diving & underwater equipment. As the technology involved in Military Diving develops, this will require a greater degree of technical support.

Administration & Logistics Department: This department would be responsible for the day-to-day administration and logistical support of the Unit. It is not envisaged that the members of this Unit would be drawn from the Clearance Diver Branch.

Counter-Mine/Counter-IED Vessel 1 & 2: WP2015 highlights the requirement to replace the two existing Coastal Patrol Vessels with vessels “with counter-mine and counter-IED capabilities” (Sec. 6.5). These vessels should have a permanent Dive Team posted as part of the Ship’s Company. The size of the proposed Dive Teams are in line with NATO Standard MCM Dive Teams, including Dive Teams posted to the Royal Navy’s MCM Vessels. When required, additional support can be drawn from the Operations Department. It is proposed that these appointments only be established when the vessels come on-line and all shore based appointments have been filled.

Defence Forces School of Diving (DFSoD): The DFSoD would be responsible for all Dive Training in the Defence Forces, to include Clearance Diver Courses, Dive Supervisors Courses, AUV/ROV Courses, ARW Combat Divers Courses, as well as currency & proficiency training for trained Divers. WP2015 highlighted the need to enhance the capabilities and to considerably increasing the strength of the ARW (para. 6.2). This will lead to a significant training burden on the NSDS in training Combat Divers and Combat Dive Supervisors. The DF Corps of Engineers are currently considering developing an underwater engineering capability. The establishment of a designated DFSoD will help accommodate these, and future, DF Dive Training requirements. As with all Naval Training, the DFSoD would fall under the Command & Control of Officer Commanding & Commandant of the Naval College (OC & CNC). “The Office of Superintendent of Diving”/ “Directorate of Dive Safety” would remain responsible for the DFSoD from a diving governance/oversight/branch management point of view.

Divers should rotate through each Department on a Bi-Annual basis in order to maintain and develop proficiency in all aspects of Military Diving.

Given the make-up of this Diving Unit, a 24/7 on-call diving response could be established and maintained. A six-person Diving Duty Watch could be drawn from all Departments and be available for out-of-hours ATCP/ATCA/Re-Compression Chamber (RCC) taskings at short notice. The Diving Duty Watch could take the following structure:

Duty Diving Officer x 1 Lt (MCDO)-CPO/Diver Duty Diving NCO x 1 PO/Diver- L/Diver Duty Diver x 4 A/Diver

Given the planned development in the Renewable Energy Sector around the Irish coast in the coming years, it is very probable that a Service Level Agreement (SLA) between the Health Service Executive and the Department of Defence for the provision of a standby RCC service will be drafted in the near future. Such SLAs were in place previously and if a new SLA was agreed, the proposed Diving Duty Watch would be essential in providing a sustainable service.

Non-Diver Support Staff would remain on the Regimental Duty Roster.

Given the technical requirements of Military Diving and the wide array equipment involved, appropriate Tech Pay should be associated with each appointment. This will be covered in Section 4 below. Tech Pay payable to Support Staff will be in line with their normal Branch appointments.

Military Diving is a physically arduous occupation and individuals must remain “in-date” from a physical fitness, medical and equipment proficiency point of view. These requirements are already laid down in NSDS Rules & Regulations. It is important to input a mechanism for when Divers become “out-of-date”. Two (2) possible Courses of Action (COAs) are suggested:

COA 1: When an individual chooses to join the Clearance Diver Branch, they should be contractually obliged to remain “in-date” for diving. Failure to do so would deem their service in the DF as being no longer required and they would be discharged on completion of their current Term of Engagement.

COA 2: Clearance Divers continue to remain professionally qualified in their original Branch and they continue to complete their Branch Career Courses. A system can be put in place where they must interview for the next promotion competition for their current rank in their original Branch and be placed on the Order of Merit List. They can then be transferred back to their original Branch

and continue their career accordingly. If no vacancies exist for the individual to transfer into or they are not deemed suitable for promotion, that individual would then not be recommended for their next Extension of Service and they would be discharged from the Naval Service on completion of their current Term of Engagement.

These mechanisms would ensure realistic promotion opportunities within the Clearance Diver Branch. These suggested COAs would need the approval of the Department of Defence, Military Management and the Permanent Defence Forces Other Ranks Representative Association (PDFORRA).

Minewarfare & Clearance Diving Officers (MCDOs) would remain as Operations Branch Officers and rotate in and out of the Unit as their career path dictates. It would be envisaged that they must remain “in-date” for Naval Diving to serve in the Unit.

In order to capture the improved capability and force multiplier nature of Military Diving, a rebranding from “Naval Service Diving Section” to “Naval Service Diving Unit” should be considered. The physical infrastructure of the new “Unit” should be improved to accommodate the proposed HR structure. Ideally, a fit-for-purpose facility should be built in a suitable location in close proximity to the Naval Ships for fleet maintenance, close proximity to maintenance support for the NSDS RHIBS, depth of water for dive training & 24/7 deployability of NSDS RHIBS; and cater for an ARW Maritime Task Unit footprint on the Naval Base.

As diving technology develops and unmanned systems become available, the argument could be made that this will reduce the overall manpower requirements. It is important to note that the objective of these systems is to “take the Diver out of the Minefield” and away from the danger area in order to reduce the risk to personnel. The manpower requirements and service support for these systems still exists from an operator, data analysis, maintenance and proficiency point of view.

It is acknowledges that much of the above detail may be deemed “down in the weeds” for the purposes of the Commission on the Defence Forces, but it is felt that it is important to demonstrate the achievability of such a proposal. However, for this proposal to succeed, it would require an increase in the overall Establishment of the Naval Service and engagement from the wider Naval Service as a whole to establish the most appropriate way of introducing the proposed Clearance Diver Branch.

4. Any other comments you may wish to make in relation to the Defence Forces having regard to the Commission’s Terms of Reference

REMUNERATION

Personnel qualifying as Naval Divers Grade 1 or 2 (on completion of a Ship Diver Course as laid down by FOCNS) are eligible for Gp 2 Tech Pay in accordance with “Conciliation and Arbitration Scheme for the Permanent Defence Forces - Conciliation Council Report (CCR) 149” so long as they remain “in-date” for diving to the satisfaction of OiC NSDS. Also in accordance with CCR 149, the following Tech Pay may be awarded to Naval Divers who achieve additional qualification and who remain “in- date” to the satisfaction of OiC NSDS:

Tech Gp 3 – Diving Grade 3 achieved. Tech Gp 4 – Diving Grade 4 achieved (to include Dive Supervisors).

Since the implementation of CCR 149, qualifying criteria for payment of Tech Gp. has been amended to reflect the evolving changes in diving qualifications. The table of equivalency is as follows:

CCR 149 EQUIVALENCY Diving Grade 1 & 2 Naval Diver Diving Grade 3 Naval Diver & 18m Supervisor Diving Grade 4 Naval Diver & 50m Supervisor

It is proposed that Tech. Gp 3-6 is payable to Divers who have obtained the following diving qualifications:

TECH. GP. AIR DIVING QUALIFICATION MIXED GAS DIVING QUALIFICATION Gp. 3 Naval Diver Gp. 4 Naval Diver & 18m Supervisor Naval Mixed Gas Diver Gp. 5 Naval Diver & 50m Supervisor Naval Mixed Gas Diver & 18m Supervisor Gp. 6 Naval Mixed Gas Diver & 50m Supervisor

Justification for Proposed Changes:

Air Diving - Since the implementation of CCR 149, the NSDS has gained civilian accreditation from the Health and Safety Executive in the UK; the International Standards Organisation of the offshore diving world. The NSDS is the only dive training body in Ireland qualifying to these international standards and therefore the NSDS is the centre of excellence for diving in Ireland.

The NSDS is also recognised by the International Diving Schools Association (IDSA) as an international dive training institute and is authorised to teach the following IDSA Diver Training Standards:

IDSA TEACHING MODULE QUALIFICATION A PREPARATORY THEORY TRAINING B COMMERCIAL SCUBA DIVER C SURFACE SUPPLIED INSHORE AIR DIVER D SURFACE SUPPLIED OFFSHORE DIVER

Mixed Gas Diving - The use of Mixed Gas in diving is new to the Defence Forces. By its very nature, it is considered technical. It considerably increases the depth and duration at depth of diving, and

increased significantly the ability of the NS to conduct searches for, and of, sunken vessels or recovery of bodies. It requires a significant step forward in respect of equipment and procedural training, as the increasingly hazardous environment in which divers may now operate, is NOT forgiving of mistakes. The risk to the Diver and the technical knowledge required of the Diving Supervisor is significantly increased when operating Mixed Gas Diving Systems. The training required and technical upskilling of a Naval Mixed Gas 50m Supervisor is especially significant as a far more in-depth knowledge of dive physiology, dive medicine, physics and emergency procedures is essential.

A comprehensive submission on Tech Pay awarded to Naval Divers was made during “The Review of Technical Grades 2-6 in the Defence Forces” process in 2019 and it is hoped that these proposed changes will be incorporated in the near future.

If the proposals made in “The Review of Technical Grades 2-6 in the Defence Forces” submission come to fruition, it is suggested that the following be introduced to reflect the appointments in the Clearance Diver Branch:

TECH. GP. DIVING QUALIFICATION APPOINTMENT Gp. 4 Clearance Diver A/Diver Gp. 5 Clearance Diver & 18m Supervisor L/Diver, PO/Diver Gp. 6 Clearance Diver & 50m Supervisor WO/Diver, SCPO/Diver, CPO/Diver

ANNEX A - CURRENT NSDS ESTABLISHMENT & STRUCTURE

LT CDR (NWC) OiC NSDS

LT (NWC) DIVING OFFICER

OPS/TRG/ADMIN MAINT. DEPT DEPT

CPO/SEA CPO/ERA CPO/MECH

PO/SEA PO/SEA (Driver) PO/ERA PO/EA

L/SEA L/SEA L/SEA L/SEA (Driver)

A/SEA A/SEA x 3 A/SEA x 3 A/SEA x 3 A/MECH x 4 (Driver)

ANNEX B – PROPOSED NSDS ESTABLISHMENT AND STRUCTURE OC NSDS OC & CNC CDR (NWC) CDR (NWC) MCDO

DEFENCE FORCES SCHOOL OF DIVING

2IC NSDS OiC DFSoD LT CDR (NWC) LT CDR (NWC) MCDO MCDO WO/DIVER NCO ic NSDS SCPO/DIVER SCPO/DIVER NCO ic DFSoD

MCM/EOD LOGS/ADMIN. **C-MINE/C- **C-MINE/C- OPS. DEPT. MAINT DEPT. DEPT. DEPT. IED VESSEL 1 IED VESSEL 2

LT (NWC) LT (NWC) LT (NWC) LT (NWC) LT (NWC) *LT (MEO) *LT (NWC) MCDO x 3 MCDO MCDO MCDO MCDO x 2

CPO/DIVER x 3 CPO/DIVER *C/ERA *C/MECH CPO/DIVER *CPO/SEA CPO/DIVER CPO/DIVER CPO/DIVER x 2

*PO/SEA PO/DIVER x 3 PO/DIVER *PO/ERA x 2 *PO/EA *PO/RRT PO/DIVER PO/DIVER PO/DIVER PO/DIVER x 2 (Driver)

*L/SEA L/DIVER x 6 L/DIVER x 2 *L/EA *L/RRT L/DIVER x 2 L/DIVER x 2 L/DIVER x 2 (Driver) L/DIVER x 4

*A/SEA A/DIVER x 9 A/DIVER x 3 A/DIVER x 3 A/DIVER x 3 A/DIVER x 3 (Driver) x 3 A/DIVER x 6

* NON-DIVER SUPPORT STAFF ** DIVING APPOINTMENTS BECOME ESTABLISHED ONLY WHEN VESSELS COME ON-LINE.

*Notes

CDR - Commander. LT CDR - Lieutenant Commander. LT - Lieutenant (NS). WO - Warrant Officer. SCPO - Senior Chief Petty Officer. CPO - Chief Petty Officer. PO - Petty Officer. L - Leading Rate. A - Able Rate. MCDO - Minewarfare & Clearance Diving Officer. NWC - Naval Watchkeeping Certificate (Operations Branch Officer). OC & CNC - Officer Commanding & Commandant of the Naval College. MEO - Marine Engineering Officer (Engineering Branch Officer MCM - Mine Counter-Measures. EOD - Explosive Ordnance Disposal. SEA - Seaman. ERA - Engine Room Artificer. EA - Electrical Artificer. MECH - Mechanician. RRT - Radio & Radar Technician.